Question ID: 3303
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Reporting Templates
Article: CIC (Annex)
Template: S.06.02
Status: Final
Date of submission: 25 Mar 2025
Question
We are struggling with a clear assignment of some assets to CIC codes, in particular 22/25/28/51. Could you please confirm that our understanding of the following instruments is correct?
1) Equity linked note with no capital guarantee but issued as senior unsecured => we believe the correct CIC subcategory is 51 (or could it be also 21 or 25?)
2) Additional Tier 1 (bank) or Tier 1 (insurance) bond => 25 (or 28?)
3) Common Tier 2 or Tier 3 bond of a bank or insurance company => 28
4) Common subordinated debt of a corporate => 25 (or 28?)
5) Perpetual profit participation right of a corporate => 25 (or 28/34?)
6) Debt-to-equity hybrid/subordinated bond => 22 (or 25/28?)
7) Knock-out certificate with physical delivery, classified as Tier 2 => 51 (or 22/25/28?)
EIOPA answer
Reporting entities are expected to apply a consistent, well-reasoned, own assessment when assigning CIC codes, considering the risks and characteristics of the respective asset.
While the question does not provide fully detailed information on all specifications of the assets, EIOPA cannot confirm a specific treatment. However, in light of the information provided, the following choices might be appropriate:
1) Equity linked note with no capital guarantee but issued as senior unsecured => we believe the correct CIC subcategory is 51 (or could it be also 21 or 25?)
51
2) Additional Tier 1 (bank) or Tier 1 (insurance) bond => 25 (or 28?)
[tier1=bonds converted to equity or written down in times of stress] 22 and 28
3) Common Tier 2 or Tier 3 bond of a bank or insurance company => 28
[tier 2=These bonds are not the first to be repaid in case of a bank's default or liquidation] 21(if bailable-in)
4) Common subordinated debt of a corporate => 25 (or 28?)
28
5) Perpetual profit participation right of a corporate => 25 (or 28/34?)
25
6) Debt-to-equity hybrid/subordinated bond => 22 (or 25/28?)
22 and 28